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Aughinish Alumina Ltd Environmental Management System Manual

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Approval Date Prepared by: 0 Kennedy Date: 3 l/05/00 D.A. Clancy EMS Manual Revised by: T. Montgomery L Fleming Revised Date: 23/02/04

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Aughinish Alumina Ltd. Environmental Management System Manual

Amendments Page

Issue 1 Quality Manual revised following preliminary Assessment-June 2000 and inpreparation for certification aduit August 2000:

Revision Date 1 26JO7JOO

Reason for Revision DNV findings Audit No. 31066

Revised by 0 Kennedy

Issue 2 Environmental Manual revised following management changes

Revision 1

Date 27/02/03

Reason for Revision Revised by Changes in Management T. Montgomery 0


Revision 2

Date 22/i o/o3

Reason for Revision Revised by Changes in the Env. Policy T. Montgomery


Revision 3

Date 23/02/04

Reason for Revision Changes in Management

Revised by T. Montgomery

Prepared by: 0 Kennedy Date: 31105100 Revised by: T.Montgomery Revised Date: 23/02/2004

Approved by the Managing Director

EMS Manual Page 2 of 35

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1

2 Statement Of Environmental Policy 6

3

0 4

4.1

4.2

4.3

4.3.1

4.3.2

4.3.3

4.3.4

4.4

4.4.1

4.4.2

4.4.3

4.4.4

4.4.5

4.4.6

4.4.7

4.5

4.5.1

4.5.2

4.5.3

4.5.4

4.6

Company Background Business Overview Environmental Policy Planning Environmental Aspects Legal & Other Requirements .Objectives And Targets Environmental Management Programme Implementation And Operation Structure And Responsibility Training, Awareness And Competence Communication Environmental Management System Documentation Document Control Operational Control Emergency Preparedness And Response Checking And Corrective Action Monitoring And Measurement Nonconformance And Corrective And Preventive Action

Records Environmental Management System Audits Management Review

Contents

Page

Purpose And Control Of Environmental 4

Management System Manual

IS0 14001 at Aughinish Alumina 7

8

9 10 II 11 12

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Prepared by: 0 Kennedy Date: 3 l/05/00 Revised by: T. Montgomery Revised Date: 23/02/2004



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1. Purpose and Control of Environmental Management System Manual (EMS)

This manual provides an overview of AAL’s environmental management system, which is based on the IS0 14001 standard.

It is specified in the scope of IS0 14001 that all the requirements of the standard be incorporated in the environmental management system. This manual briefly addresses AAL’s approach to the elements/subjects of the standard.

The manual also references aspects of the other systems (e.g. safety and quality), which form part of the EMS at AAL. The manual also incorporates the conditions of AAL’s Integrated Pollution Control Licence (IPCL) as appropriate.

A more detailed description of the elements can be found in the appropriate AAL Standard referred to in this manual. Where the EMS has been integrated into the existing safety and quality management systems these documents exist as Qualty and Environmental Standards (QES) and ISRS Standards.

Application of the principles defined in the Environmental Standards creates the need to standardise “key activities” within the company, and these methods are documented as Standard Work Methods and ISRS Procedures.

Other Records are kept to provide data for the review process and also to support IS0 14001 certification.

The relationship between the various documents is shown below.

All controlled copies of the EMS Manual are uniquely marked on the front page and are maintained and controlled as described in Quality Standard QES 001. The Managing Director is responsible for approval of the EMS Manual.

Prepared by: 0 Kennedy Date: 31105100 Revised by: T. Montgomery Revised Date: 23/02/2004

Approved by the EMS Manual Managing Director Page 4 of 35

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ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL

1 I I

I REGISTERS I

I I STANDARDS I

ENVIRONMENTAL REGULATIONS

SIGNIFICANT ENVIRONMENTAL ASPECTS

ENVIRONMENTAL OBJECTIVES AND TARGETS

ENVIRONMENTAL MANAGEMENT PROGRAMMES

I I I Prepared by: 0 Kennedy Date: 3 l/05/00 Revised by: T. Montgomery Revised Date: 23/02/04


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I ENGINEERING AND INSTALLATION l-

I MAINTENANCE t

I ILAB

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2 Statement of Environmental Policy

Protection of the environment is a high priority for every employee, contractor and director of Aughinish Alumina Ltd. This objective requires our full co- operation in a continuing effort to improve our products and production processes.

The process we employ at Aughinish, the ‘Bayer Process’, is the accepted industrial method for the manufacture of alumina worldwide. Our principal product, smelter grade alumina, is used to manufacture aluminium, a metal with many recognised environmental benefits.

Successful integration of our environmental objectives with our health, safety, quality and cost objectives is required to ensure our competitive position.

We will continue to:

Comply with all legal requirements and where appropriate, use more stringent internal standards based on our expertise

Use worldclass practices to ensure that we prevent pollution and meet social, economic and environmental demands.

Develop opportunities with suppliers and customers to improve our products and to minimise waste and environmental impacts.

Make effective use of environmental management systems that continually improve our performance consistent with defined goals. Review our environmental objectives and targets regularly to ensure that these remain both relevant and appropriate to our operations.

Communicate with employees, consumers, communities, businesses and government to achieve greater environmental understanding.

Ensure that Aughinish’s environmental policy is communicated to all employees and contractors and is made available to the public.

By fulfilling these objectives, we will have due regard to the environmental expectations of our many stakeholders.

Damien A Clancy Managing Director

gfh September 2003

I I I Prepared by: 0 Kennedy Date: 3 l/05/00 Revised by: T. Montgomery Revised Date: 23/02/04


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3 IS0 14001 at Aughinish Alumina

Aughinish Alumina Ltd (AAL) is the largest alumina refinery in Europe, yet it is situated in rural Ireland. It is essential therefore that through superior environmental management practices, we minimise our impact on the surrounding environs. We do this through our environmental management system.

The IPCL requires the company to establish and maintain an Environmental Management System and the conditions of the licence outline the form that the EMS should take at AAL. In order to demonstrate its commitment to environmental protection, AAL has gained certification of its EMS to the international standard IS0 14001.

Certifying our existing EMS to the 14001 standard gives independent recognition to AAL’s management system, make our environmental performance transparent to interested parties and facilitate greater awareness of the standards and controls in place at Aughinish.



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4 Company Background

Aughinish Alumina Ltd (AAL) operates an alumina refinery near Askeaton in Co. Limerick.

The company is owned by Glencore Ltd, of Baar, Switzerland. It is a “tolling” operation producing in excess of 1.5 million tonnes of metal grade alumina per year using Bayer Process technology.

The owner supplies bauxite ore, finances the operation and uplifts finished product for delivery to the customers.

Operation of the site within guidelines set by the parent company is entirely the responsibility of local management. Safety, quality and care of the environment are key objectives.

Product is predominantly shipped as alumina from our own marine terminal. Additionally, a significant proportion of our production is sold as alumina trihydrate.

Over 400 people are employed on the site.

Prepared by: 0 Kennedy Date: 3MJ5100 Revised by: T. Montgomery Revised Date: 23/02/2004

Approved by the EMS Manual Issue 2 Managing Director 4 Page 8 of 35 Revision 3

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4.1 Business Overview OPEIkATING PLANT I

D I Main Process

r-l Circuit

LOCAL 2 FILTRATION & MUb WASHING

Y LoCAL3 PRECIPITATION

LOCAL 5 BOILERHOUSE

I

LOCAh HYDRATE

FILTRATION & CALCINATION

LOCAL 4 PORT& RAW MATERIALS

- FOYNES PORT

(As emergency only)

4

HUMAN - RESOURCES &

PUBLIC AFFAIRS

FINANCE ‘I TECHNICAL &

- MATERIALS

Prepared by: 0 Kennedy Prepared by: 0 Kennedy Approved by the EMS Manual EMS Manual Issue 2 Date: 3 l/05/00 Date: 3 l/05/00 Managing Director Managing Director Page 9 of 35 Revision 3 Revised by: T. Montgomery Revised by: T. Montgomery Revised Date: 23/02/2004 Revised Date: 23/02/2004

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4.2 Environmental Policy

The AAL Environmental Policy as given above has been communicated to all employees and contractors. It is on display at prominent locations around the plant.

The policy shall be reviewed at least annually at the management review meeting and amended if the organisational goals or customer expectations change.

Environmental objectives and targets shall be reviewed annually to ensure that these remain relevant to the Policy.

The Aughinish Alumina environmental policy shall be signed by the Managing Director with the full support of the Aughinish Alumina board of directors. The signature of the Managing Director signifies the support of the Aughinish Alumina Ltd Board of directors.

Reference: IS0 14001 Section 4.2



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4.3 -Planning

4.3.1 Environmental aspects

Aughinish has established a procedure for regularly examining the environmental aspects of its operations, both direct and indirect. The aspects are ranked for significance and aspects, which give rise to significant environmental impacts, are then listed in the Register of Significant Environmental Aspects.

0

Reference: IS0 14001 SWM 7512

ER 002 series

Section 4.3.1 Maintaining a Register of Significant Environmental Aspects Register of Significant Environmental Aspects



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4.3.2 Legal and other requirements

Aughinish Alumina maintains a register of all Legislative, Regulatory & Policy environmental standards that are applicable to its operations.

The register is reviewed and updated annually. Updating will normally be co-ordinated by the environmental co-ordinator in liaison with others. The final responsibility of identification, collection and interpretation of the documentation resting within the team. Changes in the legislation shall be traceable.

The register shall be managed by Aughinish’s environment team.

Reference: IS0 14001

SWM 7511

ER OOlA ER 001 B

Section 4.3.1 Section 4.5.1 Maintaining a Register of Environmental Regulations List of Environmental Regulations Database of Environmental Legislation

Prepared by: 0 Kennedy Date: 3 1105100 Revised by: T. Montgomery Revised Date: 23/02/2004


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4.3.3 Objectives and targets

Aughinish Alumina maintains a Register of its Environmental Objectives and Targets. The objectives and targets of the management system stem from the company’s environmental policy statement. The objectives and targets are reviewed on an annual basis and amendments notified to the EPA per IPCL conditions.

The management of Aughinish Alumina also establishes objectives to ensure that the internal programmes of the Environmental Management System are functioning properly.

The EMS objectives will address continuous improvement of systems performance.

Reference: IS0 14001 EPOI SWM 7513 ER 003 IPCL

Section 4.3.1 Environmental Policy Statement Maintaining Environmental Objectives, Targets Register of Objectives .& Targets Condition 2.2

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4.4 Implementation and Control

4.4.1 Structure and responsibility

The Aughinish Alumina Organisation is described as a flat structure with a minimum of hierarchical layers. Authority may be derived from function or occupation as well as from line managerial position:

Production, maintenance and engineering are managed in five production departments denoted as Locals 1, 2, 3, 4 and 5. Other departments fulfil a support role to the front line activities carried out in these Locals.

The following three charts outline: -the organisational structure, -an overview of the business operations, -the organisation’s reporting’ line.



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&Y!& *WWsh Alumina Ltd.

T%s Environmental Management System Manual

Calcination, Port, Materials Services

Plant Technology Accounting Staff

Vessel Turnaroun Pump Maintenance

HR, HSE & Public Affairs

Manager

-t Public Affairs

Environment

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I Managing Director

Document Controller

L

I

Engineer Technologist Training & Development HR/PA Administration Security Staff

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Roles, Responsibilities & Authorities

Roles & Responsibilities

The Manaqing Director The Managing Director has ultimate responsibility for all activities on the AAL site. The MD and the six Managers who report to him form the Management Team.

The Manaqement Team

Hydrate Plant Manager

(Locals 1, 2 & 3)

Calcination, Port, Utilities & Eng Manager

Technical and Process development, laboratory, development Materials Services of information systems, purchasing and storage Manager of materials and services, Energy related issues

Financial Controller (Company Secretary)

Modernisation Manager

Human Resources and Public Affairs Manager

Operation, Maintenance and Development of the Hydrate plant comprising Local 1 (Digestion), Local 2 (Filtration and Mud Circuit), Local 3 (Precipitation). Process Control & Operations Site wide.

Operation and Maintenance of Local 4 (Port), Local 5 (Calc. & Utilities), Maintenance / Project Engineering for AAL and Contractors. Development of Maintenance Site wide.

Accounting Staff

Scope,designandconstructCHP Plant and Plant Optimisation project.

Safety, health, security, training and development, HR and Recruitment, Environment. Communications with press and local community

The Environmental Co-ordinator with personnel from engineering, HR and the management team form the EMS Steering group for the IS0 14001 programme and has specific responsibility for this task.

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Co-ordinator Co-ordinator is a senior position in the organisation. The holders of this role are in general qualified to degree level. Their main responsibilities include facilitation and development of professional staff and improvement initiatives and developments in their area of responsibility. Co- ordinators report to Managers.

Environmental Co-ordinator The Environmental Co-ordinator is the management representative as defined in IS0 14,001 (Section 4.4.1). He is responsible for managing the documented environmental management system on a day-to-day basis and ensuring its conformance with the international standard. The Environmental Co-ordinator is assigned responsibility and authority for the overall management of the Environmental System from the Managing Director.

The Environmental Co-ordinator’s quarterly report to the management team is an input to the evaluation of performance in the Management Review and is used as a basis for improvement of the system.

The Environmental Co-ordinator is the ‘person in charge’ as defined in the IPCL (Condition 2.8)

Facilitator Team Facilitators are responsible for the performance and development of operations and maintenance teams. A key feature of their role is to assure that all their team members have sufficient competence to fulfil their duties, including such skills as interpretation of instructions, priority setting, troubleshooting and decision-making. Team Facilitators report to Managers but have communication role to the coordinator in their area.

Prepared by: 0 Kennedy Date: 3 l/05/00 Revised by: T. Moqtgomery Revised Date: 23/02/04


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Support Facilitators provide support for Shift operation, Technical resource and site contract operations. Support Facilitators report to Co-ordinators.

The Shift Plant Facilitator (SPF) is the ‘person in charge’ as defined in the IPCL (Condition 2.8) outside normal working hours. He reports all incidents/accidents in the ‘Shiftlog’ and in the case of emergency he will contact the Environmental Co-ordinator as soon as practicable.

Environmental Facilitators are responsible for advancing environmental awareness in their area. Environmental Facilitators liase with the Environmental Co-ordinator.

Enoineer The engineer holds an engineering degree or equivalent 3rd level qualification. Their responsibilities include evaluation of operational and maintenance criteria, review and recommendation of best practice, and the verification of results. Engineers report to Co-ordinators.

Operators/Crafts persons Operators and crafts persons are organised in teams. They are responsible for the operation and maintenance of the plant. All crafts persons are “time served”. Both operators and crafts persons are further qualified by ongoing internal and externally provided skills training. At least five days training per year is allocated to each employee.

Gontol Room Oroerator (GRO) The control room operator is the central figure in the operating shiff learns with regard to (he w-trul of [he prtxess and the safeguarding of the environment to achieve required results. The CR0 works proactively to ensure that the process is optimised through constant monitoring and control using the DGS, PI and other information/control tools.



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Aughinish Alumina Ltd; Environmental Management System Manual

Environmental team The main role of the environment team is to consult and appraise line management and to monitor, evaluate and report the Environmental Management System performance. The team will also have an important role in the development and maintenance of the Aughinish Alumina Environmental Management System.

Technolooist/Analvst Technologists and Analysts provide a technical service in the plant. These include Process, Maintenance, Project and Environment Technologists and also Laboratory Analysts.

Buver Buyers are involved in the purchasing and procuring of goods and services. These are routine consumables and spares; major raw materials (HFO, Caustic, Lime) and equipment for construction projects; together with construction and other specialist services, which include waste management. Their aim is to source the best supplier to meet the plant needs, get the best value for money and ensure that our internal customers receive the best possible service.

Loss Control Co-ordinator (LCC) The role of a LCC is to overview of any planned process/project changes, to ensure that (i) that any proposed loss control measures are appropriate to the perceived hazards and (ii) the Environmental Co-ordinator is notified of any changes to process that may require EPA approval.

Internal Auditors Aughinish has a large pool of auditors, selected from all levels in the organisation and are trained by certified trainers. The audit programme and audit team selection ensure an independent approach.

Prepared by: 0 Kennedy Date: 3 l/&/O0 Revised by: T. Montgomery Revised Date: 23/02/04


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&b’& Au@ inish Alumina Ltd.

TXY Environmental Management System Manual

Document Controller The Document Controller is responsible for storage, distribution and administration of documents in the Quality System, Environment and Management System (and ISRS). The Document Controller is the only person authorized to change documentation on the dedicated network drive.

Document Holders Each audit centre has a Document Holder, who is responsible for administration of documents particular to their area in the Quality System, Environment and ISRS Management System.

Resources An annual budgeting exercise is conducted to ensure adequate material, financial and human resources are deployed to meet the needs of the business. The training needs of the workforce are established annually to ensure an adequate level and mix of skills.

Reference: IS0 14001 Section 4.4.1



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Aughinish Alumina Ltd. Environinental Management System Manual

4.4.2 Training awareness and competence

Recruitnient is based on education, training and /or experience. Job specifications are available for identified positions, with competence being assessed at interview stage using interview plans.

Documented procedures are followed for identifying training needs and provision of training for AAL personnel performing activities affecting all aspects of operating the business. Ail employees are qualified to carry out their work and hold appropriate trade or professional qualification and/or have received suitable in-company training. Training records are maintained for each employee.

AAL is certified to Level 8 of the International Safety .Rating System (ISRS), which defines specific requirements for employee training. The training system at AAL is certified to Excellence Through People Standard since 1997. This certification is awarded by the National Training Authority, FAS.

Through the training plans AAL will train its people to be aware of their individual roles and responsibilities in achieving conformance with the IPCL, environmental policy and with the requirements of the EMS.

Reference: IS0 14001 Section 4.4.2 QES 010 Training S WMs - 9000 series Human Resources IPCL Condition 2.7

Prepared by: 0 Kennedy Date: 3 l/05/00 Revised by: T. Montgomery Revise.d Date: 23/02/04


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4.4.3 Communication

Aughinish has developed a communication process, which includes (i) reports (ii) meetings (iii) publications, (iv) audit feedback and (v) training sessions.

Training sessions and team meetings are organised to raise awareness among employees and contractors, of the company’s EMS and its requirements.

External communication programmes are an IPCL requirement and also part of Aughinish’s programme to promote knowledge and understanding of the Aughinish operation. Regular ‘Neighbours Meetings’ provide a format for dealing with concerns of interested parties and complaints are dealt with by AAL’s corrective action procedures. Members of the public may view environmental performance information at the Aughinish Visitors’ Centre where facilities are provided to view the environmental data.

The environment team regularly publishes environmental performance information and maintains an environment page on the company’s Intranet. AAL also maintains a site on the Internet, which provides information about the company’s activities including environmental issues.

Reference: IS0 14001 SWM 7509 SWM 9100

SWM9101

Section 4.4.3 Communication of Environmental Issues Provision of performance information to the Public

Handling of Environmental Complaints SWM 7508

IPCL lntranet Page Internet Page

Provision of Environmental Information to the Regulatory Authorities Condition 2.9 http://thenet/ http://www.aughinish.com/

0

0

Prepared by: 0 Kennedy Date: 31/05/00 Revised by: T. Montgomery Revised Date: 23/02/04


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4.4.4 Environmental management system documentation

AAL’s environmental management system documentation is summarised by this EMS manual. A brief overview of AAL’s Environmental Management System documentation can be found above in section 1 of this manual. At the top level of the system is the Environmental Policy, which is a statement by AAL Management of the thrust and direction of our EMS. At the next level are the Standards, Manuals and Registers and at the lower levels are SWM, Procedures and Records.

Standards define the policy or general approach, selected for the key elements of AAL’s EMS. These are linked to the elements of the IS0 14001 international standard. Where the EMS has been integrated into the existing safety and quality management systems these documents exist as Quality and Environmental Standards (QES) and ISRS Standards.

AAL has a generated a series of ‘Registers’, which detail the company’s (i) Objectives and targets (ii) Environmental Regulations and (iii) Significant Environmental Aspects.

The Waste Management/Maintenance/Engineering and Installation and ILAB Manuals outline the systems in use in AAL including definitions, responsibilities, controls, procedures and organisation.

Application of the principles defined in Standards is documented as Standard Work Methods or ISRS Procedures.

In support of these SWM and Procedures AAL maintains a system of records and record control to demonstrate that control has been exercised in the operation of its business and provide data for improvement of that business.

Reference: IS0 14001 EM 001

Section 4.4.4 Environmental Management System Manual



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4.4.5 Document control

A comprehensive system is in place to ensure that adequate, accurate, current and valid documentation is maintained and that such documents are available at appropriate locations in the workplace and employees are trained in their content. The system permits changes to be made to such documents provided the specified approvals are obtained.

Control of access to and storage of data - held on the plant computer network system - is defined in written procedures. These procedures maintain adequate back up, including disaster recovery plans, and outline precautions for virus protection.

Controlled documents and records are stored on access protected network memory sectors only. Diskettes, local computer hard disks, compact disks, or any other portable electronic data storage media are not authorised for the storage of controlled documents or records.

Reference: IS0 14001 QES 001 IPCL

Section 4.4.4 Document and Data Control Condition 2.5

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I I I Prepared by: 0 Kennedy Date: 31105100 Revised by: T. Montgomery Revised Date: 23/02/04


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4.4.6 Operational control

AAL has identified activities and processes, which affect or have the potential to affect the environment. Such activities are carried out under controlled conditions with particular attention will be paid to the following:

Operational Practices Where production processes pose a significant environmental risk, operating practices contain specific procedures and work instructions to prevent or minimise the environmental impact.

Modifications to the process can only be made in compliance with the AAL Process Change procedures as outlined in the Engineering and Installation Manual. This has a specific environmental risk assessment procedure.

The manufacturing process is supervised and controlled by a computer based Distributed Control System (DCS) which covers all key operations on the site.

Changes to product specifications occur only after detailed review between owner(s) and AAL technical personnel with involvement of owner(s) commercial personnel. The review will also consider the environmental implications (legislative or otherwise) of such changes to production.

Maintenance Maintenance of equipment to ensure continuing process control is achieved by application of the principles defined in the AAL Maintenance Manual. Equipment is categorised according to its criticality and then subject to condition-based preventive, planned or breakdown maintenance (as appropriate). Control of equipment maintenance is contained in a QES ‘standard.




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Procurement and Contracted Services Written procedures ensure that purchased materials are ordered and supplied in accordance with drawings and/or specifications issued by AAL. ,

All suppliers are selected on their ability to meet order requirements and placed on an approved vendor list.

Surveys of incoming materials, products, equipment and chemical substances determine which items require a written specification to control safety, health and environmental problems. Incoming materials are inspected as stated in the Purchasing Standard and SWMs to ensure that they meet or exceed the requirements of the AAL specification.

This system of material and service management ensures that incoming resources are evaluated and controlled.

Compliance with plant safety, health and environment standards as well as legislative standards is specified as a condition for all bids and contracts. All contractors are supplied with a list of environmental regulations. This document outlines regulations applicable to contractors to ensure protection of the environment while they carry out workat the AAL site. Contractors are obliged to comply with the company’s Management Systems (i.e. IS0 9002, IS0 14001 and ISRS).

Waste Disposal All waste materials arising at AAL are disposed according to

AAL'sWasteManagementmanual(WM001). Waste arising at AAL can be segregated into 30 different waste streams. Each waste stream has a specific disposal procedure, which contains instructions for the collection, disposal and record keeping associated with that stream. Reference is also made to a list of waste contractors, which have been approved by the EPA to dispose of AAL’s waste.



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AAL also logs the quantity of waste disposed on a monthly basis.

Reference: EMI 001 MM 001 QES 004 QES 014 QES 005 QES 006 QES 015 QES 012 S WMs - 1000 series S WMs - 2000 series S WMs - 3000 series S WMs - 4000 series S WMs - 5000 series S WMs - 6000 series S WMs - 7000 series S WMs - 8000 series Critical Task Procedures WM 001 NDE Survey standards SF01901

AAL Engineering and Installation Manual AAL Maintenance Manual Contract Review Maintenance Purchasing Bauxite Quality Control Alumina Storage and Dispatch Sampling and Laboratory Testing Local I local 2 Local 3 Local 4 Local 5. Workshop/Site services Technical PurchasingStores Plantwide Waste Management Manual

MSDS Approval Form




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Emergency preparedness and response Plans are in place to respond to accidental events such as major spills, fires or “Acts of God”.

Aughinish Alumina has a fully trained and properly equipped emergency response team. This team conducts regular drills and rehearsals and formally evaluate the effectiveness of the plans at least annually.

The organisation will review and revise, its emergency preparedness after periodic tests and real emergencies and implement any changes required.

Reference: IS0 14001 ISRS SO07 ISRS PO07 Series SF00702 Series IPCL

Section 4.4.7 Emergency Preparedness Emergency Response Procedures Emergency Preparedness Test Schedules Condition 11


Approved by the EMS Manual Managing Director Page 30 of 3 5

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.4.5 Checking and corrective action

4.51 Monitoring and Measurement Criteria for on-line monitoring, sampling and analyses of environmental parameters are specified in the IPCL. AAL has established procedures for reliably measuring and reporting environmental performance and compliance with IPCL schedules. AAL’s system of sampling and testing ensures that an adequate degree of control is exercised over its aspects. Samples are analysed on-site in accordance with the Laboratory Quality Manual. The laboratory is accredited to ILAB standard. The laboratory is to schedule the accreditation of those analyses, which are not within the present scope of ILAB system at AAL. In the interim they are controlled with reference to /LAB requirements.

The company set out calibration and maintenance schedules in defined lists for equipment and instrument, which are used to monitor the environmental performance of the plant.

Each team at AAL regularly reviews their own performance against targets and identifies and agrees actions for improvement.

The register of regulations will be reviewed and updated on a regular basis. Changes in the legislation, which affect operations at AAL, shall be notified to the management team and reviewed at the Management Review.

Reference: QES 012 ILAB Documentation SWM 0003 QES 016A QES 016B SWM 7516 SWM 7513 QES 013 QES 007 SWM 7511

Sampling and Laboratory Testing

IPCL Compliance Monitoring Calibration of Field Instruments Calibration of Laboratory Instruments Environmental Performance Index Maintaining Environmental Objectives and Targets Performance review Management review Maintaining a Register of Environmental Regulations

Prepared by: 0 Kennedy Approved by the EMS Manual Issue 2 Date: 3 l/05/00 Managing Director Page 3 1 of 35 Revision 3 Revised by: T. Montgomery Revised Date: 23102104

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4.52 Nonconformance and corrective and preventive action

AAL maintains documented procedures, including defined responsibility and authority, for handling and investigating non-conformance incidents and for initiating corrective action(s).

Corrective and preventive action procedures exist for resolution of problems, which include significant adverse effect on achievement of objectives & targets, environmental performance and include:

0 Discrepancies’ found during internal audits, which cannot be easily resolved by the auditee.

a Actions arising from complaints. . Actions arising from non-compliance with IPCL

conditions and recordable environmental accidents.

Preventive action is addressed in the first instance by maintenance of the “Business Plan” and achievement of the targets set therein and includes operation of a ‘Hazard Log’. The management team regularly reviews plant performance, including the performance of the environmental management system, and initiates preventive actions as appropriate.

The Environmental Co-ordinator has the responsibility and authority to review non-conformances and comment on their effectiveness.

Reference: IS0 14001 SWM 9101

SWM7505 Section 4.5.2 Handling of Environmental Complaints

Classification of Environmental Accidentsllncidents SWM 0004 CAR Procedure QES 007 Management Review QES 008 Corrective & Preventive Action ISRS SO05 Accident/incident Investigation ISRS PO0501 Accident/Incident Investigation Reporting and

Categorisation AAL Plant Capability Study IPCL Condition 2.6


Approved by the EMS Manual Managing Director Page 32 of 3 5

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4.5.3 Records

AAL maintains accurate records in order to demonstrate compliance with the requirements of the environmental management system and to record the extent to which planned environmental objectives and targets have been met.

Such records are properly stored, can be readily recovered and persons responsible for their maintenance are specified. Their retention times is established and recorded.

Reference: QES 009 IPCL

Records Condition 11

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Aughinish Alumina Ltd. Environmentat Management System Manual

4.54 Environmental management system audits

Internal audits are conducted to assist in ensuring that AAL operates in line with the documented environmental management system and to provide a basis for continual improvement. The scope and timing of the audits is defined in a planned programme and employees who are qualified conduct the audits.

External auditing is carried out by regulatory authorities and by the certification bodies. The purpose of these audits is to assess compliance with licences, standards etc. The scope and timing of these audits are defined by the licensingkertifica tion bodies.

Records are kept of the audit findings and any resulting follow-up actions.

Reference: QES 002 SWM 005 lSRS PO01 .Ol

The Audit and Review Process Auditing of SWM & Other Operating Procedures Managing Director’s / Senior Managements’ System Compliance Tour

SWM 007 Physical Conditions Audit




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4.6 Management Review

The Management Team reviews the performance and effectiveness of the environmental management system at quarterly intervals.

The review process shall consider Aughinish’s EMS in relation to current environmental issues, policy and regulations.

This meeting is conducted according to a formal agenda and the minutes are endorsed by the Managing Director.

Reference: IS0 14001 QES 007

Section 4.6 Management Review



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Aughibish Alumina Ltd.

Standard Work Method

Title: Area 34A Produce stackable mud &

Maintain mud removal capacity.

1.0 Objectives The objective of the SWMis to ensure that the mud circuit is run with the lowest inventory of mudpractical with respect to theplantproduction rate while at the same time producing good quality stackable mud. The quantity of mud recyled through the filtrate system must also be minimized at all times through goodJilter operation.

2.0 Reference The 34A samples are referred to in the Routine Work Schedules ’ Manual(RWSM) of the Sampling and Laboratory Testing Standard QS 012.

3.0 Responsibilities l The Control Room Operator (C.R.O.) is responsible for, monitoring mud

throughput and mud line pressure. l The Process Operator (P.O.) is responsible for, sampling, field patrols, filter

checks, pump checks, filter washing and mud line pressure control. the P.0 to take off each filter, wash its cloth and trough, and wash vents daily on lA, lB, 2A, 2B, 3A, 3B and 3 times weekly on 50A/50B

l The Process Engineer is responsible for monitoring and achieving all long term trends and process targets.

4.0 Detail:

4.1. Mud Removal rate in practice is based on the torque and mud dip in Tank 6.This torque and mud dip will dictate how many filters should be run and at what speed they should be run at. The torque to target should be in the range of 0.8 to 1.2, reducing filter speeds followed by taking filters off line if torque falls below this range and mud dip is Smeters. Conversely, bringing extra filters on line followed by speeding up online filters if torque is above this range and mud dip is less than 5 meters.

4.2 Mud capacity -

a) If filter(s) not performing (typically$Ztering between 25 - 35 m3/7zr), the CR0 or P.O. checks or adjusts the following:

l Tank 6 underflow solids. (TyQicai target range 37 - 43%) Prepared by: Local 2 Team Date: 4/10/1996. Revised by: Joe Vaughan Date : 28/01/2003

Approval Name Signature @a&

M.McG. C.R.0 T.O’D. C.B.

Reference No: SWM 2009,

I

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Aughinish Alumina Ltd.



Maintain mud removal

I capacity.

l

Synfloc addition on to Tank 6. Mud getting onto take off roller. Mud being combed off evenly across full length of take off roller. Is the seal water on to the Filter Control Head? Filter vacuum system (-50-70kpa) Cloth condition, blinding, holes, scale buildup (may require caustic washing). Filter cake properties , filter may need to be dumped + washed , cake may contain a lot of sand, cake maybe slimey (too much synfloc cut it back 12/24hr delay). Filter rotation speed and level (speed 40-80%, level 50-80%). Increase filter speed if all available filters insufficient.(see SWM 2010) Reduce water addition if filter being stripped of mud.

b) Poor mud pump capacity (each pump not able to handle 1 ‘/z filters) check: l Cylinders for restriction and burst diaphragm. l Oil reservoir levels. l Oil make-up device faults. l Reactor level instrument. l Restriction in mud re-circulation line.

Cl Minimise mud in A34 filtrate Solids check to be carried out daily using imhoff cone at Tank-28A-15. Target is ~100 ml/l. Results to be inputted on DCS. If result is >lOO ml/l then check condition of each filter cloth, check for tears/holes and repair as required. Further investigation may be required, in this case the filtrate at each filtrate pump should be checked for solids to identify the filter causing the problem.

43, Mud linepressure The typical target range for the mud line pres&re is between 6000 and 8000 kpa. The mud line pressure is likely to deviate below this target range when the Jilters are being washed or when the mud discharge point is being changed in A54. Extendedperiods of low mud line pressure usual& coincide with the mud discharge point being changed to the East Ridge in A54 but should still be investigated to ensure that the mud quality is as good as possible. Other

Prepared by: Local 2 Team Date: 4/10/1996. Revised by: Joe Vaughan Date : 28101/2003

Approval Reference No: Issue Name - Signature Date SWM 2009 1

M.McG. Page 2 of 3 Revision C.R.0 5 T.O’D. C.B.

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Maintain mud removal capacity.

parameters that effect the mud line pressure is the condensate dilution flow to filter take-offtroughs and Reactor 55. This should be minimized at all times. Condenste addition should be increased ifthe mud line pressure increases beyond 8500 kpa as the Mud Pumps will trip at 11,OOOkPa. If Mud Trucking is in operation then the Mud Line pressure will be reduced to allow for smoother operation.

4.4 Filter washing The P.O. to take off each filter, wash its cloth, trough and vents daily on lA, lB, 2A, 2B, 3A, 3B and 3 times weekly on 50A/50B Each on-line filter should be washed daily. The wash should be valved onto the vent plate during this washing operation. The Operator should report blocked vents to the Process facilitator such they may be hi-jetted.

4.5 Caustic Washing The local should try and caustic wash two Jilters per week for a 12 hour

duration.

4.6 Patrolling The P.O. carries out Field Patrols 3 times per shift and logs items for attention.

Prepared by: Local 2 Team Date: 4/10/1996. Revised by: Joe Vaughan Date : 28/01/2003

Approval Reference No: Issue Name Signature Date SWM 2009 1

M.McG. Page 3 of 3 Revision C.R.0 5 T.O’D. C.B.

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Title: Area 34A Mud Washing Operating

Guidelines.

1.0 Objectives:

Eficient mud washing < 8 gpl on weekly average basis. The operating philosophy for the area in terms of Soda control is to have as much filtration area available as possible, with the filters operating at the slowest speed possible.

2.0 Reference ‘The 34A samples are referred to in the Routine Work Schedules Manual(RWSM) of the Sampling and Analysis Schedule on o: drive.

3.0 Responsibilities The Control Room Operator ( C.R.O.) is responsible for, monitoring wash flow and filter speed The Process Operator ( P.O.) is responsible for, sampling , field patrols , wash distribution and cloth repairs .

4.0 Detail:

4.2 Sample mud corn each operating filter for gpl soda daily.

4.2.1 Target wash barflows should be 7M3 on thefiont and 15M3 on the back. 4.2.2 Minim&e flow from area 27 to tank 15. 4.2.3 Minimise sumpings from area 65 to tank 15. 4.2.4 Maximise % solids in clarifier under flow to avoid pumping from clarifier to tank

15.

0 4.3 FILTER SPEED:- Run filters normally at minimum speed. :- Old filters = 0%. New filters = 40%. Only increase speed if required mud removal rate cannot be achieved with all available filters.

Prepared by: Local 2 Team Revised by: Joe Vaughan Date: 22/l O/l 996. Date Revised :

Approval Reference No: Issue Name Signature Date SWM 2010 1

M.McG. T.O’D. Page 1 of 2 Revision T.B. 3

12/2/02

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Title: Water Management

1.0 Objectives:

l To manage the effluent streams reporting to A34 so that contaminated streams are recovered back to the plant as much as possible.

l To manage plant pond levels. @ To minimize the power corzsrcmption in the area by ruming the effluent

system as efficiedy as possible i.e. run the nzinimwn number of SWP & L WY ptmps when possibk

0 Reference

2.1 The 34A/54A samples are referred to in the Routine Work Schedules Manual(RWSM) of the Sampling and Laboratory Testing Standard QS 012, IPCL no. 35.

2.2 Abbreviations: C.C.M.T. = Contaminated Condensate Make-Up Tank W.E.D.T. = Waste Effluent Disposal Tank S.W.P. = Storm Water Pond I.P.C.L. = Integrated Pollution Control Licenses

3.0 Responsibilities

l The Control Room Operator (C.R.O.) is responsible for monitoring pond levels and stream distribution. C.R.O. to report non-compliances to Shift Plant Facilitator. (S.P.F.)

l S.P.F. to report non- compliances in the shiftlog. l The Process Operator ( P.O.) is responsible for sampling, field valve set up

and field patrols. l The Environment Coordinator will notify the Environment Protection Agency

(E.P.A.) as soon as practicable regarding I.P.C.L. non-compliances.

Prepared by: Local 2 Team. Date: 8/3/95 Revised by: Colm Cribbin Date: 27/8/04

Approval Name Signature

Facilitator P.Engineer CR0

Reference No. Date SWM 2011

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4.0 Detail:

0 A34 annex stream distribution

F Explanation

y recovering streams back into the plant, both caustic losses and acid usage associated with ffluent can be reduced. If the streams reporting to A34 annex are managed correctly, ubstantial savings can be made.

The normal stream distribution should be as follows:

WP B-line recirculation

I I I South Pond I

Pond Water Tank

WP I

CCMT levei control The CCMT goes to make up the level in the wash water tank, tank 15. The flow out of the CCMT is governed by the net wash. If the net wash is low (typically less than 6Om3/h) then no make up flow from the CCMT will be needed. Therefore adding streams to the CCMT may only cause the tank to overflow to the drain leading to the West pond.

Prepared by: Local 2 Team. Date: 813195 Revised by: Colm Cribbin Date: 27/8/04

Name Approval Signature Date


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The following are general guidelines where flows should report to in order of preference

Bird Sanctuary l Pond Water tank via the 6A pump l SWP via the 6B pump

(* N.B. the 6A pump should always operate first and the 6B pump should only operate when the BS level cannot be controlled by the 6A pump on its own)

. West Pond . CCMT l Pond Water Tank. l SWP if the West Pond Level is > 50%.

. East Pond l Pond Water Tank. . CCMT

. Stormwater Pond l South Pond via the 10” line. l To the Pond water tank via the 8” line should it not be possible to get

sufficient West pond in to maintain the pond water tank level or if the SWP water inventory >200,000m3.

. A.41 Seal Water To CCMT or Pondwater tank if informed

. The Turlough Sump to 20 m clarifier

. Area 34 Seal Water Return To Pond water tank

Prepared by: Local 2 Team. Date: g/3/95 Revised by: Colm Cribbin Date: 27/8/04

Approval Name Signature


Reference No. Date SWM 2011

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SWP water inventory control

4.2.1 Recover sufficient SWP via the 10” line to keep level <95% (normal recovery rate: Winter 250m3/h, Summer 1 OOm3/h). Jilf&s I0~l is few e1202gh in the SWP

cc~zd the fvt2rrnfiwn to r~2e~~~nr is low tl2sn there sftould he oniy f S

nmning.

. At 175,OOOm3 volume, the SWP is full. At 200,000m3: l Increase the SWP return rate to maximum if not already there. This involves

maximizing the daily total effluent flow to the Shannon, without breaching the EPA license.

l Use SWP in place of West pond as make up to the Pond Water tank. Maximise site-wide usage of pond water.

l At 300,000m3, after agreement from the Environment Department, the effluent flow may be increased above 17,280m3.

l At 350,000m3, after agreement from the Environment Department, the solids limit (50mgl) may be raised to release the bottleneck at the clarifier.

l Raising these limits are considered actions of last resort.

4.4 Patrolling The P.O. carries out field patrols in the area each shift.

Prepared by: Local 2 Team. Date: 8/3/95 Revised by: Colm Cribbin Date: 27/8/04


Facilitator P .Engineer CR0

Reference No. SWM 2011

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T!!i!!i



Title: Effluent Neutralisation and Discharge

1.0 Objectives:

To discharge neutralised effluent meeting both the Integrated Pollution Control License (IPCL) conditions, and our own internal targets.

Maximum discharge volume in one day: 17,280 m3

(i.e. equivalent to an average daily flow of 720 m3/h)

l Maximum discharge rate per hour: 770 m3

l Discharge pH:

- 6.0 - 9.0 (IPCL)

- 6.5 - 8.5 (internal)

l Discharge solids:

- 50 mg/l

l Discharge temperature: the method of monitoring this is yet to be agreed with the EPA.

l Discharge BOD: 1500 kg/day

Note:

l Unless otherwise stated the targets above are not internal targets.

2.0 Reference

The 34;4/54A samples are referred to in the Routine Work Schedules and in 4.5 below

Manual(RWSM) of the Sampling and Laboratory Testing Standard QS 012.

3.0 .Responsibilities

Prepared by: Local 2 Team Date: 22/10/1996 Revised by: Pat McMorrow Date: 15/10/2003


L2 CR0 TMontgomery DMcEnery MMcGrath J Moore CBrassill


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l The Control Room Operator ( CRO) is responsible for controlling pond levels, monitoring samples, monitoring results and trends, pH control, solids control, monitoring discharge effluent flows.

l The Process Operator (PO) is responsible for sampling as per the sampling and analysis schedule, field patrols, field valve set ups.

4.0 Detail:

4.1 35 Meter Effluent clarifier operation

Explanation

The clarifier is designed to settle the solids generated by the neutralisation process. The amount of solids to be settled depends on the feed flow and the caustic concentration of the feed - higher caustic means more Bayer process liquor, which in turn means more solids. Several factors are required to settle these solids:

l Sufficient flocculant must be added.

l The clarifier should be operated at as high a pH as possible. At higher pH less gas is produced in the neutralisation reaction. This carbon dioxide gas which is formed as sodium carbonate is broken down under acidic conditions, can lift the solid particles to the surface.

l Solids from the clarifier underflow should be recycled back to the feed. This allows the solid particles entering the clarifier to grow in size, making

I them easier to settle.

4.1.1 The south pond

4.1.1.2 The level in the Fresh acid tank should be maintained above 40%.

4.1.1.3 The pH in the buffer tank (0506 pH) should be set between 7.5 - 8.3 pH

4.1.1.4 Spent acid from Local 1 should be taken in at a rate that does not drop the 0506 pH below its setpoint. The spent acid flow controller should be run in CASCADE mode to avoid this.

Date: 15/l O/2003



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Title: Efjuent Neutralisation and Discharge

4.1.1.5 If pH < 7.0 then foaming will result and solids settling will be very poor. Call E/I to check probe if foaming occurs and pH reading is > 7.0 (suspect faulty calibration on pH probe).

4.12 Flocculant addition

Explanation

When the solids loading on the clarifier increases, more flocculant is needed. Increased solids loading can result from increasing the clarifier feed flow or from increased caustic concentration in the feed. Increased acid usage is an indication that the feed caustic concentration has increased.

The performance of the flocculant solution can also vary, depending on the batch strength. The lower the concentration, the more effective the flocculant will be, because it will mix better with the clarifier feed.

4.1.1.6 Add sufjcientflocculant to maintain the clariJier interface between -3.0 and -4Sm, this will keep the fee&e11 submerged in the solids blanket which will reduce the O/F solids concentration. Flocculantflow to the clartfter should normally be run in Cas mode. If the interface rises the flocculant to feedflow ratio can be increased (34FCO161). Once control of the interface has been regained, then theflocculantflow should be reduced again to prevent the solids becoming over-flocculated. Over flocculation produces sticky solids which may cause raking problems.

4.1.1.7 Theflocculant should be dosed into the feed inlet pipe of the 35m clartfier.

4.1.1.8 The batch concentration should be in the range.of 0.15 to 0.25%. Should a batch be made up that is signt>cantly weaker then previous batches then switch to the standbyjlocculant make up unit.


Name Approval Signature


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4.1.3 % Underflow solids control

Explanation

By recycling the underflow solids back into the feed, the capacity of the clarifier to settle can be increased. As the solids from the underflow are continuously recycled around, they grow in size, which makes them settle faster. As the particles grow, it causes the % solids in the underflow to increase, from typically 1% without recycling, up to 20%. As a basic rule, the higher the underflow % solids, the greater will be the settling capacity of the clarifier.

Other factors also affect the % underflow solids:

l Over-flocculation can poison the solids and prevent them from growing.

l If too much solids are pumped out the % solids will drop. The solids are normally pumped to tank 15, however if required they can be pumped to A27.

l If the blanket overflows then the u/f solids will be lost over the top of the clarifier.

4.1.2.1 If the U/F solids go above 8% they may go septic and cause a smell. If the solids are above 8% decrease the synfloc and reduce the feed flow if the blanket is above the target.

4.1.2.2 The recycle flow controller should be set in CAS mode, the set point will typically be the feed flow * 0.3

4.1.2.3 The u/fpump rate is controlled automatically by the blanket. The blanket Se? Point is typically -3&t, Running the blanket at this level will improve the solids in the overflow.

4.2 20 Meter Clarifier operation

4.2.1 Under normal operation process condensate and the Turlough should be the only streams lined up to the 20 Meter Clarifier.

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Title: Effluent Neutrulisation and Discharge

4.2.2 The operation of the 20m clarifier is the same as the 35 m clarifier except the solids loading is much lower and a stable blanket is never established

4.2.3 The pH in the buffer tank (0076 pH) should be set between 7.8 - 8.3 pH

4.2.4 The recycle flow controller should be set in Auto at . 1 OOm3/h

4.2.5 Theflocculantflow is typicah’y between 0.5 and I m3/h

4.216 To remove the solids that build up in the clartfterpump the u&to tank 15 for 2 hours every week..

4.2.7 If the 20m clartj?er is offline the process condensate should be sent to the WEDT. ThepHselpoint of the WEDT overfEow (048pHprobe) should be in the range 6.5 - 7.5. Should there be a problem with high pH in the liquid waste pond (L WF) then this pH should be reduced in preference to reducing the pH of the 35 meter clartjier.

4.3 Liquid Waste pond operation

4.3.1 The effluent pumped to the Shannon@om the L WP must comply with the targets as per section 1.0 above.

4.3.2 The level should be pumped automatically between the high and low level trip points. The high level should be between 60 to 90%.

4.3.3 Ifthe pH is outside the internal limits, put LWP on recirculation mode, until pH comes back within limit.

4.3.4 If there is a drift of > 1 .O pH units between the probes on the ‘A ’ and ‘B ’ lines, when pumping down both to the Shannon, then E/I should be contacted to check calibration. There is an additionalpHprobe on the B line to the Shannon. This can be used to trackpHproblems resulting from Area 82. Area 82 has its own e@uentpHprobe also. The tags are 54ATOO13 and 82ATOOO2.


Approval Reference No. Issue Name - Signature DA SWM 2012 1

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4.3.5 Sample both lines to the Shannon for suspended solids on a 24 hour basis (Isolock). Use the on-line solids meters for continuous solids measurement. If the solids dtrerence on both lines, when on-line, exceed 30 mgll then E/I should be contacted to check calibration.

4.3.6 IL according to the solids meters, the solids exceed the internal target then theflow to the Shannon should be shutdown and the level in the pond allowed to rise until it is safe to resume pumping. I$ according to the lab sample, the solids have exceeded the internal target, then the low level trip should be raised by 5%.

4.3.7 If the total&w to the Shannon during any one day reaches the daily volumetric limit, then the L WP pumps will automatically shutdown. The CR0 will receive an alarm should the hourly average flow exceed the maximum limit. Flow down one of the e&Sent lines should be shutdown or throttled in this instance.

4.4 Patrolling

The PO carries out Field Patrols of the area once a shift and logs where appropriate items for attention.

4.5 Dust control

4.5.1 If the mud stack contractor requests water to the sprinklers start both the LWPpumps ifthey are not already running. If the level in the L WP is below the min. trip point then put the lines in recirculation.

4.5.2 Get the field operator to check that the sprinkler valves on

the discharge of both L WP pumps are open.

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5.0 Effluent Samples Names and Numbering

Effluent to waste Pond 34-5

South Pond 34-6

Storm Water Pond 54-3

Clarifier Underflow 34-8

35mmClarifier Overflow 34-9

20mmClarifier Overflow

I) 34-10




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Aughinish Alumina Ltd. Title: Pond Clean Outs and Inspection.


1. Objectives

l To provide practical methods for the clean out of all Local 2 ponds, so that sufficient storage capacity for effluent/liquor can be maintained within them during both normal and emergency situations.

l To provide practical methods for the inspection of all Local 2 ponds, so that any leaks may be identified and repaired.


l The Local process engineer and facilitator are responsible for deciding when a clean out may commence and where the clean out sludge should be disposed of.

l The control room operator (CRO) is responsible for monitoring any condensate dumps to the West pond or its trenches.

l The process operator (PO) is responsible for monitoring the pump off of the liquid waste pond, during a normal clean out.

l The Local environmental facilitator is responsible for inspection of ponds.

l The civil engineering department is responsible for monitoring any repairs to the pond liners or concrete.

3.0 Detail

3.1 West pond clean out and inspection

3.1.1 The pond should be cleaned out on an as needs basis, depending on the level of mud build up within the pond. Typically, it should be cleaned once per year.

3.1.2 The Local process engineer or facilitator will decide when the clean out can commence.

Prepared by: AF, TM, LF Date: 19/08/98

Revised by: PMcM,

Date: 14/10/03

Approval Name Signature CR0 TM DMcE JM MMcG CB


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3.1.3 The process engineer should inform other Locals of the need to avoid dumpings into the pond while the clean out is taking place. The Local CR0 should follow up on any dumps that do occur.

3.1.4 Prior to the clean out commencing, if the level in the pond greater than 50%, then it should be lowered by the normal means, by pumping the , liquor back to the process. If this cannot be done, then it will be necessary to pump off to the storm water pond (SWP).

3.1.5 All flows into the pond must be diverted elsewhere:

3.1.5.1 Local 1 bad condensate lined up to Ta-28A-0 15

3.1.5.2 All trenches into the pond to be bunded off.

3.1.5.3 Build up of liquor within the bunded trenches to be pumped to an agreed location (typically the SWP)

3.1.6 When the level in the West pond has dropped below 50%, depending on the level of mud build up in the pond, the Local process engineer or facilitator will decide when it is appropriate to stop returning liquor from the pond back to process. This is to avoid large quantities of mud being pulled out of the pond and sent back to the process. At this stage, any more liquor pumped out from the pond should be directed to the lagoon

3.1.7 Agitators can now be put in the pond and the slurry pumped to the lagoon. Or pumped into trucks and disposed on the stack.

3.1.8 Once the slurry level has reached an agreed level a confined space permit is put on the pond. This will allow the contractor to put

mechanical equipment into the pond to complete the cleanout.

3.1.9 As the pond is not lined with a plastic membrane, mobile mechanical plant can be used in the pond, to assist in removal of the mud slurry. The slurry can be loaded into trucks with a front-end loader

Prepared by: AI?, TM,LF Date: 19/08/98

Revised by: PMcM

Date:l4/10/03

Approval Name Signature Date CR0 TM DMcE JM LF

Reference No. Issue SWM 2017 1


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Aughinish Alumina Ltd. Title: Pond Clean Cuts and Inspection.


3.1.10 The Local 2 Environmental facilitator or process control engineer will decide when the clean out is complete or when it is necessary to stop due to a rising pond level.

3.1.11 Pumping from the pond back to the process should not be resumed if there is a significant build up of solids directly around where the liquor is drawn out of the pond.

3.1.12 Should an inspection of the pond be required, then the following additional steps will be taken during the clean out:

3.1.13 Inspection of the pond floor will be done by the Local 2 environmental facilitator or the civil engineering department or by a delegate.

3.1.14 Concrete repairs to the pond floor should be completed by a competent civil engineering contractor before bringing the pond back into service.

3.1.15 The L2 Environmental Facilitator shall record the details of the inspection and any repairs carried out to ensure WP integrity against leakage. Details shall be copied to the Environment Department electronic record system, which is also used for process drains and sumps inspections.

3.1.16 The L2 Environmental Facilitator records the details of the inspection and any repairs carried out to ensure WP integrity against leakage. Details are copied to the Environment Department electronic record system, which is also used for process drains and sumps inspections.

3.1.17 The L2 Environmental Facilitator or process control engineer records the dry tonnes of solids removed from the pond andinforms the Data Analysts and Environmental department.

3.2 Liquid Waste Pond clean out and inspection

Prepared by: AF, TM,LF Date: 19108198

Revised by: PMcM

Date:14/10/03

Approval Name Signature CR0 TM DMcE JM


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Title: Pond Clean Outs and Inspection.

3.2.1 When the liquid waste pond (LWP) low level limit (see SWM 2012) reaches 65% then the pond should be cleaned out. Ensure the South pond level is as low as possible prior to the clean out.

3.2.2 Shut down the 35 m and 20m clarifiers, this will stop all flows to the LWP.

3.2.3 Pump the LWP down to its low level limit as per normal operation and then shutdown the flow from the pond to the Shannon.

3.2.4 Spray the pond with Bio odour neutraliser (MAN no. 1004) using a bowser and tractor. Dilute 100 litres of Bio odour neutraliser in a 5000 litre bowser.

3.2.5 Monitor the Hydrogen sulphide (H$S) every 2 hours using a Drager hand pump and 0.2 to 5ppm Drager tubes. If the dragger tube reads any H$S then get the pond re-sprayed and check again. Repeat until the dragger tube reads ~0.2 ppm H$.

3.2.6

3.2.7

Using Pu-54A-003 pump from the LWP to the mud stack lagoon.

The PO should monitor the pump out of the LWP at least twice per shift.

3.2.8 The process facilitator or engineer will decide when the clean out is finished. At this stage all of the A34 annex and LWP operations can be returned to normal.

3.2.9 The LWP low level limit should now be reset to 60% by the CRO.

3.2.10 Should an inspection of the LWP be required then the following

additional steps willbe required during the clean out: 3.2.11 The sludge material not removed from the pond at this stage should be

taken out by a combination of sludge agitation and pumping. This must be achieved by a method, which does not involve putting mobile

Prepared by: Approval AF, TM,LF Name Signature Date: 1 g/08/98 CR0

TM Revised by: PMcM DMcE

JM Date:14/10/03 LF

CB


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mechanical plant onto the LWP plastic liner in order to avoid damaging this membrane liner.

3.2.12 Inspection of the liner will be done by the Local 2 environmental facilitator and/or by a delegate. Any holes/defects found should be marked with indelible paint.

3.2.13 Liner repairs should be completed by a specialist contractor before bringing the pond back into service.

3.2.14 The L2 Environmental Facilitator shall record the details of the ’ inspection and any repairs carried out to ensure LWP liner integrity. Details shall be copied to the Environment Department electronic record system also used for process drains and sumps.

3.2.15 The L2 Environmental Facilitator or process control engineer records the dry tonnes of solids removed from the pond and informs the Data Analysts and Environmental department.

3.3 South pond clean out and inspection

3.3.1 The pond should be cleaned out on an as needs basis, depending on the level of solids build up within the pond.

3.3.2 Spray the pond with Bio odour neutraliser (MAN no. 1004) using a bowser and tractor. Dilute 100 litres of Bio odour neutraliser in a 50001iter bowser.

3.3.3 Monitor the Hydrogen sulphide (H$S) every 2 hours using a Drager hand pump and 0.2 to 5ppm Drager tubes. If the dragger tube reads any H2S then get the pond re-sprayed and check again. Repeat until the dragger tube reads ~0.2 ppm H2S.

Prepared by: AF, TM,LF Date: 19/08/98

3.3.4

Approval Name Sknature CR0 TM DMcE JM LF

The Local process engineer or facilitator will decide when the clean out can commence.

Date:14/10/03 I

Reference No. Issue g&e SWM 2017 1

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3.3.5 Pump the South pond level down to near the solids level as per normal operation and then shutdown the flow from the pond to the clarifier.

3.3.6 Switch all the effluent streams out of the South pond and line them up into the annex.

3.3.7 Blind the South pond discharge line to the 35m clarifier. Blind the 10” SWP return at the discharge of the SWP pumps. Open the valves to send the South pond discharge down the 10” SWP and on to the lagoon.

3.3.8 Agitators can be put in the pond and the slurry pumped to the lagoon. Or pumped into trucks and disposed on the stack.

3.3.9 Once the slurry level has r-cached an agreed level a confined space permit will be put on the pond. This will allow the contractor to put mechanical equipment into the pond to complete the cleanout. The third of the pond nearest the Varisco pump is concreted so only this section ,can be driven on.

3.3.10 The process facilitator or engineer will decide when the clean out is finished. At this stage all the A34 annex operations can be returned to normal.

3.3.11 The L2 Environmental Facilitator or process control engineer records the dry tonnes of solids removed from the pond and informs the Data Analysts and Environmental department.

3.4 Storm Water pond clean and Mud stack perimeter channel out and inspection

3.4.1 A method to cleanout the Storm Water pond and Mud stack perimeter is currently been developed. This method will allow the pond to remain

on line and requires no mechanical access into the pond. This section of the SWM will be updated when this method is developed and proven in the field

Prepared by: Approval Reference No. AF, TM,LF Name Signature Date I SWM 2017 Date: 19/08/98 CR0

TM Revised by: PMcM DMcE Page 6 of 6 Revision

JM 2 Date:14/10/03 LF

CB

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Title: Operation of Sanitary Effluent Treatment System

1.0

2.0

Objectives & Scope

To establish good and safe operating practices for the A82 Activated Sludge Process Sanitary Effluent Treatment Plant. In addition, the procedure is designed to ensure that the discharged effluent is within specification as required under the Integrated Pollution Control Licence.

Definitions & Cross-references

2.1 Integrated Pollution Control Licence No 35 Schedule 2(iii)

2.2 IS0 14001 Section 4.5.1 Monitoring & Measurement

2.3 Abbreviations:

BOD Biochemical Oxygen Demand

COD Chemical Oxygen Demand

IPCL Integrated Pollution Control Licence

MLSS Mixed Liquor Suspended Solids


Local 2 CR0 is responsible for monitoring effluent compliance. Local 2 four cycle operators are responsible for operation of the plant when Local 2 day operators are not on site.

Local 2 day operator(s) will carry out operation of the plant. Local 2 crafts personnel will carry out maintenance/calibration.

The Local 2 day operator(s) will carry out desludging and sludge land spreading.

Sampling, laboratory analysis and analytical records will be the responsibility of the Environmental Technologist(s).

4.0 Detail

4.1 Description of the Process

Sanitary effluent contains organic (carbon containing) matter. If discharged to the environment, naturally occurring bacteria feed on this matter and convert the

Prepared by: Approval Reference No. Issue BHB, OK & AMF Name Signature Date SWM 2018 1 Date: 13104199 T Montgomery

Revised by: Pat McMorrow

Date: 6/2/2004

G Haugh D McEnery L Fleming J Moore T O’Dwyer


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carbon to carbon dioxide, consuming oxygen in the process. In a river, this depletes the oxygen level and may lead to fish kills (particularly Salmonid species such as salmon and trout during low summer flows when the water is warm and dissolved oxygen is already lower than normal).

The sanitary effluent system uses these naturally occurring bacteria to breakdown the organic matter prior to discharge. Oxygen is supplied to the aeration chamber by the blower and air sparges to ensure that aerobic conditions (> 1 ppm dissolved oxygen) are maintained for a healthy biological population. As they feed, the bug population (activated sludge) increases and must be controlled. Regular desludging ensures this. Excess solids are removed in the clarifier settling chamber and returned to the aeration chamber where the activated sludge is stored.

The treatment plant is a biological living system. It is intolerant to pH shocks > 0.5 pH units caused by acid or caustic, toxic shocks by oil or other chemicals and also to excessive flow which may flush the biological population from the plant.

The untreated effluent and activated sludge in the A82 treatment plant may contain biological pathogens, etc. It is recommended that:

4.2

0 All persons coming into contact with this plant or the liquids in it (including laboratory samples) are inoculated with Hepatitis A vaccine as a precautionary measure,

a Persons with cuts or damaged skin should avoid contact with the plant. It is recommended that latex gloves be worn as a barrier against infection. Good hygiene is observed. Hands and face should be washed before consuming food or liquids, etc. after working on the treatment plant.

Operation

4.2.1 IPCL Limits There are legal requirements contained in the IPC Licence regarding the operational control of the plant, these limits apply even during emptying/desludging and

Volume to be emitted: Maximum in any one day : Maximum rate per hour :

PH

240 m3 82 FT0008BT 10m3 82 FB 0004MX 6-9 82 AT 0002.PV

BOD 25 mg/l

Suwended Solids I 35 mg/l I 82 HU 900 1 .LI 1

Prepared by: BHB, OK & AMF Date: 13/04/99 Revised by: PMcMorrow 6/2/2004


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Normal Onerating Conditions Under normal operating conditions area 82 works as follows:-

l Sewage is pumped from the influent pit to the treatment plant via the 2” untreated sewage line. The flow is controlled by KFY-82A-004.

l Once the sewage has been treated it overflows into the effluent tank and is pumped via PU-82A-003 to the Shannon through KFV-82A-011. Before it gets to this valve the pH is checked with pH probe KAT-82A-002 to ensure pH compliance. And the suspended solids are checked with the solids meter KAT-82A-016 002 to ensure suspended solids compliance

l If the pH of the influent to the system rises the bacteria will be unable to treat the sewage. pH control is achieved by acid addition to the treatment plant after the influent pH is measured by KAT-82A-001.

Recirculation Conditions

l When the effluent pH KAT82A002 goes above 8.5 or below 6.5 the solenoid valve the river (KFV-82A-0 11) closes and the recirculation valve KFV-82A-12 opens. This stops pumping to the Shannon and sends the effluent into recirculation. If the pH is high the field operator must open the manual valve to return the effluent to the influent pit. If the pH in the influent pit increases acid will be added to return the pH to the set point of 7.8. If the effluent pH is low the CR0 will get the alarm Low pH: Valve to OLD PIT. The field operator must then open the valve to the old effluent pit and close the valve to the influent pit. The flow will not go back to the river until the effluent pH KAT82AOO2 is between 6.5 and 8.5

l When the efluent solids go above 33mgpE on 82AB0016 the solenoid valve the river (KFV-82A-011) closes and the recirculation valve KF’V-82A-12 opens. TheJield operator must then open the valve to the old effluent pit and close the valve to the infuentpit. And investigate why the solids are high. If the blanket is above 45cm@om the top the day op&-ator will have to desludge the tower immediately. The CR0 should then select recirc on CR0 select recirculation mode target, this puts the effluent into continuous recirculation. The effluent must not be pumped to the Shannon until the tower is desludged. when the tower is desludged the CR0 should select off on the CR0 select recirculation mode. If the CR0 doesn ‘t select recirc the effluent will remain in recirculation until the value qf 82ABOOl6 goes below

BHB, OK & AMF Reference No.

SWM 2018

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3Omgpl then recirculation valve KFV-82A-12 closes and the valve to the river KFV-82A-01 opens, and the flow goes to the river.

On visual inspection, by the operator(s), the mixed liquor should appear brown in colour with a faint earthy odour and the clarifier liquor should be clear to a depth of approximately 45 cm.

The environmental technologist(s) should be contacted to sample the effluent for analysis and for advice if the plant condition is seen to be deteriorating.

The sampling, analysis and inspection protocol for the plant is detailed in Table 1.

In the event of a non compliance the Environmental Co-Ordinator should be informed on day shift or the Shift Plant Facilitator should be informed outside of 0 normal day shift hours.

4.2.2 Desludging the System

Desludging is carried out under the instruction of the Environmental Technologist(s) i.e. when the MISS is greater than 2000 mg/l. (The volume to be removed is calculated from the value of the MLSS in the tank.)

Do not stop the aeration when desludging, as it is easier to estimate how much sludge to remove when the aeration is on.

Withdraw one bowzer load (9 m3) of MLSS fi-om the aeration bath for 2000- 3000 mg/l MLSS and two loads in excess of 3000 mg/l MLSS.

Withdraw sludge from the bottom of the aeration chamber using a vacuum tanker, starting at the feed end.

The sludge should be disposed of by land spreading on the area designated in the IPC Licence (west of perimeter road at A54 to jetty). The procedure for disposal of the sludge is detailed in the Waste Management Manual (4.3.1.9 Disposal of 0 sanitary sludge).

Records of the quantity disposed, the location and date will be sent to the Environmental Technologist who will maintain a record as required by the IPC Licence.

If the bowser used is not dedicated to A82 fill and empty twice with clean water before and after use.

4.2.3 Restarting the Treatment Plant following Process Upset

BHB, OK & AMF

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In the event that microscopic and visual inspection indicates that the culture is dead or depleted, a fresh batch of activated sludge will be have to be added to the treatment plant. Contact the treatment plant and request one to two bowser (9 m3) loads of activated sludge (approximately 3,000 mg/l MLSS) to be delivered into the aeration chamber of A82. Contact Andy Welsh - County Works Engineer - Treatment Plant (Mobile 087 2074886) Newcastle West Treatment Plant (phone 069 62188, Operator Mobile 086 8444503), Haulier: Ruttle Agricultural contractors - Ballingrane, Askeaton, contact - Alan Ruttle (069) 64237, 087 2531484 / 087 8237768 (mobiles). Sludge is normally free of charge but there is a charge for haulage.

Also 80 litres of Biotreat AB, 20 1 of Bio-activator and a bag of zeolite can be added to aid recovery. This can be purchased from Bio-Industries Ltd (Phone 01 294 1025) and used to restart the unit.

5.0 References

a Operating Manual A82 Sanitary Effluent Treatment System

l Aughinish Alumina Integrated Pollution Control Licence (27/5/98)

0 Waste Management Manual - 4.3.1.9 Disposal of Sanitary Sludges

0 MSDS Biotreat AB- number 661

MSDS Bio-activator - number 662 , 0

0 The control strategy is outlined in the document on DCS actions from the Hazop stored in the Local 2 BP1 document folder

Prepared by: BHB, OK & AMF Date: 13/04/99 Revised by: PMcMorrow 6/2/2004


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Table 1 Sampling, Analysis & Inspection Protocol (* a grab sample to be taken until continuous sampler is installed)

Parameter Frequency of measurement Normal/ Target IPCL Limit Responsibility BOD Influent (mg/l) As Required 250-400 Envir Techn’l BOD Treated Effluent (mg/l) Weekly grab 5-20 25 Envir Techn’l COD Treated Effluent (mg/l) As Required 45-65 Envir Techn’l Suspended Solids Treated Effluent (mg/l) Weekly grab 5-20 35 Envir Techn’l MLSS (mg/l) Weekly 2000 - 3000 Envir Techn’l Dissolved Oxygen (ppm) As Required 1.5 - 2.5 Envir Techn’l

Microscopic examination of MLSS As required Active biological population - Envir Techn’l free from filamentous elements

Settlement Test (30 mins settled solids) Weekly 200 - 600 Envir Techn’l pH (influent and treated effluent) Continuous 6.5 - 8.0 6.0-9.0 Flow (m3/h) Continuous 5-6 10 m3/h (max). Manually set - Local 2

240 m3/day (max). operator Visual inspection (aeration tank) Daily on normal working days Brown in colour Local 2 operator

Faint earthy odour Clarifier liquor clear to 45 cm depth

pH, dry matter, organic matter, Annually None specified Envir Techn’l phosphate, nitrogen and heavy metals (sanitary sludge)

BHB, OK & AMF

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Aughinish Alumina Ltd. Standard Work Method

Title:

Dust Emission Control and Frost Precautions - Local 2

1.0 OBJECTIVE AND SCOPE

l To avoid dusting from the mud stack and the roadways in Local 2. l Take frost precaution to prevent freezing of lines and sprinkler heads.

Dusting occurs when particles of process residue becomes airborne. The potential for dusting is increased when weather conditions are both dry & windy.

2.0 DEFINITIONS AND CROSS-REFERENCES

2.1 2.2 2.3 2.4

EN IS0 14001 4.4.6. SWM 0003 IPCL Compliance Monitoring SWM 7505 Classification of Environmental Accidents/Incidents ISRS POO5.01 Accident/Incident Investigation, Reporting & Categorisation

3.0 RESPONSIBILITIES

In consultation with the Local 2 Co-ordinator the Contractor has responsibility for managing the Mud Stack. He visually checks the mudstack for signs of dusting on a daily basis and will take all the necessary precautions to prevent dusting.

The 4 cycle operator will check the mudstack for dusting at least twice per dayshift at weekends (Contractor not normally on site at weekends).

The Shift plant facilitator will check the mudstack for dusting at least once per dayshift at weekends.

If dusting is happening on the mudstack this is a plant emergency. The plant emergency number 4444 must be used to contact security.

Security have a list of people who are trained to operate tractor/bowser/raingun. The list includes fire crew members, Local 2,4 - cycle shift operators, 2 - cycle operator, day operators and Contractors.

Prepared by: Approval Reference No. M McGrath & DMcE Name Signature j& SWM 202 1 Revised by: MMcG/

Date: OS/OS/O2 D McEnery Revised Date: 08/04/03 Mick McGrath

Page 1 of 4

Liam Fleming Rob McLean

Issue 2

Revision 1

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Title:

Dust Emission Control and Frost Precaustion - Local 2

Security should immediately phone people on site from this list and inform them that the mud stack is dusting. Security should also phone contractors and request that they come on site immediately if not already on site. Contractors have their own tractor/.bowser. Security must phone the mud stack contractor, and request that he come on site. The Contractor is the best person to manage the dust control operation and direct people on the optimum operation of sprinklers.

Security should inform the Local 2 co-ordinator and the Environmental Co-ordinator that the mud stack is dusting.

The assembly point is the water tank at the LWP. The SPF decides with the group which sprinkler points to pressurise and a plan of action. When Contractor arrives on site he will manage the operation. A water header tank has been installed which will enable the sprinklers to be operated from the central discharge.

Once sprinklers are being operated the area needs to be assessed and cover arranged for the next shift (s) if necessary.

4.0 DUST CONTROL STRATEGY

4.1 4.2

4.3 4.4 4.5 4.6 4.7

Minimise mud flat area exposed to dusting risk. Keep mud flats in service as long as possible to limit areas of potential dusting. Switch points regularly to cover drying mud with wet mud. Maximise mud solids to the stack to get best stacking angle. Switching mud points regularly to aid stacking angle lift. Water spray sprinkler pipe lines installed in most areas. Five No. bowser units available to transport and discharge water form the Liquid Waste Pond. AAL Bowsers left at LWP at weekends. If taken to be used elsewhere on site, must be returned to LWP and filled with water.

4.8 Open individual valves on sprinklers for approx. five minutes at a time and rotate as required.

Prepared by: M McGrath & AMF Date: 08/08100

Reference No. Issue SWM 202 1 2

Revised Date: 08/04/03 Page 2 of 4 Revision

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Title:

Dust Emission Control and Frost Precaustion - Local 2

5.0 FROST PRECAUTIONS

5.1

5.2

5.3

If temperature at weather stations drops to 0°C it will be necessary to take frost precautions. Set up alarm from weather station. Open discharge line of PU-54A-02/03 to the stack to central manifold and to East Ridge. Install valves on lines which have blanks and drain down the lines.

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Prepared by: M McGrath & AMF

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Reference No. Issue 1 SW-M 202 1 1, 2 1

Date: 08/08/00

Revised Date: 08/04/03

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Title: Area 54A Mud Stacking.

1.0 Objectives:

A. To achieve the maximum life from the mud-stack B. Achieve a stacking angle greater than 1%. C. To avoid any incidence of dusting beyond our boundaries.

2.0 Reference

l SWM 2009 Produce stackable mud & Maintain mud removal capacity. The key to the success of any mud-stacking strategy is the adherence to SWM 2009 in maintaining mud pressure.

l Aughinish Alumina Ltd - Mudstack Operational Manual. This manual is compiled as a condition of the IPCL fi-om the EPA.

l Landfill Status Report to EPA. This report updates the progress on actions agreed with the EPA. (

3.0 Responsibilities The Process Operators (P.O.), working as a team with the Site Process Materials Contractor, are responsible for the day to day running of the area. Their responsibilities include:

1. Patroling the area and deciding which mud discharge points are to be operated and their operating duration.

2. Assessing the vulnerability of dusting and deciding on appropriate measures to suppress it.

3. Submitting job-tickets for any maintenance work required. 4. Take part in the formulation of longer-term strategies in conjunction with

the Local 2 Coordinator and his team.

The Local 2 Coordinator with support from the Central Engineering Dept manages the construction of rockfill embankments on the periphery of the mud- stacking areas.

4.0 Detail: Prepared by: Tom Murray Date: 4/10/1996. Revised by:

Date : 25/06/2003

Name Approval Reference No: Signature Date SWM 2022

Issue 1

DMcE T.O’D TH TM


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4.1. Mud Stacking

4.1.1. General Approach.

Title: Area 54A Mud Stacking.

The general approach to be taken is to practice what is called in the business ‘Field Stacking”. This simply means that the mud is directed to a particular area

for a short period of time. Then the mud is directed to another area allowing the ftrstportion of mud to mature. The preference is to have, at any one time, at least Jive mudpoints available for thisJieId stacking methodology. This allows the mud to mature more quickly, which in turn enables the mud to be stacked at a higher angle in the long term and also enable earlier trespass onto the stack surface.

4.1.2. Routines.

a) The Process Operator maintains regular communication with the mud stack Contractor. They agree on the mud-points to be used and operate the appropriate valves to achieve this. Particular importance is placed on their decision on how to operate over the weekend.

b) The mud stack Contractor coordinates the dump truck movements in the area to ensure that Sand, Oxalate, turnaround contents and Lime tailings are deposited in the correct areas.

c) The Process Operator relays any concerns on Mud quality to the Local 2 CR0 or Operations Facilitator.

d) The Process Operator and the mud stack Contractor report any safety or environmental incidents or concerns to the local 2 Operations Facilitator.

e) The Process Operator monitors the operation of all pumps in the area and submits any maintenance requirements through the Job-ticket system.

For detail see SWM2021

4.3 Review of Operation.

Prepared by:

Date : 2510612003

Approval Name Signature Date

DMcE T.O’D TG

Reference No: SWM 2022

Issue 1

Page 2 of 3 I Revision

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Title: Area 54A Mud Sacking.

The Local 2 coordinator will convene at Zeast quarterly review of the operation of the mud stack and minutes of these meetings wiZZ beJiled electronica&. The typical agenda to be followed will be:

1. Safety management. 2. Dust suppression management. 3. Engineering and construction activity. 4. Status of actions from the Landfill Status Report 5. Other environmental issues. 6. Review of mud stacking for the previous period. 7. Review the SWM. 8. Strategy for the next quarter

The Site Process MateriaZs Contractor, the L2 Operations Facilitator, L2 Process Operators, a Plant Environmental Dept. representative and the Civil Engineer will typicazly attend the review to be chaired by the Local 2 Coordinator.

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